Description: This article provides a short history of the correction procedures previously developed to address compliance failures and the shortcomings of those procedures under sections 101f and 7702, laying the foundation for a sea change in the correction process.

Description: This article discusses tax rates used in computing toll charges for closing agreements with respect to corrections under IRS section 7702.

Description: Interplay of §807(f) and the stat cap in §807(d) as there continues to be uncertainty as to whether a change to the stat reserve could be subject to §807(f).

Description: This article provides an alternative method to the computation of the Reduction in Benefits Test under 7702A. Part 1 provided for reduction in death benefits. Part 2 provides for reduction in Qualified Additional Benefits.

Description: This article is a discussion about the life settlement industry and the tax considerations for life insurance bought and sold in the secondary market.

Description: This article discusses final Treasury Regulations published in October 2019 under Internal Revenue Code sections 101 and 6050Y. The regulations cover new tax reporting requirements for transfers and sales of life insurance contracts, as well as changes to the transfer-for-value rules related to reportable policy sales

Description: This article discusses a new procedure for correcting inadvertent failures to satisfy the diversification requirements applicable to variable annuity and life insurance contracts under section 817h of the Internal Revenue Code.

Description: On January 19, 2005, the Treasury Department and the Internal Revenue Service the “Service” responded to a life insurance industry request for guidance on the treatment of qualified additional benefits “QABs” under sections 7702 and 7702A of the Internal Revenue Code through the release of Revenue Ruling 2005-6 the “Ruling”.

Description: This article considers PLR 201304003, which addressed the application of Internal Revenue Code section 1035 to the exchange of a survivorship, or “second-to-die,” life insurance contract after the death of one of the insureds for a new life insurance contract covering only the life of the surviving insured.

Description: On June 17, 2019, the Internal Revenue Service published Final Regulations implementing changes to loss reserve discounting under section 846 of the Internal Revenue Code made by the Tax Cuts and Jobs Act. This note addresses changes made in the Final Regulations, particularly modification of rules for determining the interest rate used for discounting, in response to comments from taxpayers on the proposed regulations.